Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 614

Declaration of Harold J. McElhinny in Support of Apple's Motion to Compel Production of Documents and Things filed byApple Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Jacobs, Michael) (Filed on 1/11/2012)

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Exhibit E 425 MARKET STREET SAN FRANCISCO CALIFORNIA 94105-2482 TELEPHONE: 415.268.7000 FACSIMILE: 415.268.7522 MO RRI SO N & F O E RST E R L LP N E W YO RK , SAN F RAN C I SCO , L O S A N G E L E S, P A L O A L T O , SAC RAME N T O , SAN D I E G O , D E N VE R, N O RT H E RN VI RG I N I A, WASH I N G T O N , D .C. T O K YO , L O N D O N , BR U SSE L S, BE I JI N G , SH AN G H AI , H O N G K O N G WWW.MOFO.COM December 28, 2011 Writer’s Direct Contact 415.268.6024 MMazza@mofo.com Via E-Mail (marissaducca@quinnemanuel.com) Marissa Ducca Quinn Emanuel 1299 Pennsylvania Ave. NW, Suite 825 Washington, D.C. 20004 Re: Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.) Dear Marissa: Apple requests that Samsung agree to substantially complete, by January 23, 2012, its production of sketchbooks, CAD, and physical models to the extent not already covered by my December 6, 2011 letter and the Court’s December 22, 2011, Order, as follows: All Samsung sketchbooks (or similar hand drawings, however created, stored, or archived) depicting designs for any Samsung phone product, tablet product, or touchscreen digital media player, regardless of where sold, whether for a final design or an alternative design that was not commercially released. All CAD drawings (or other schematics that Samsung uses to design its products) depicting designs for any Samsung phone product, tablet product, or touchscreen digital media player, regardless of where sold, whether for a final design or an alternative design that was not commercially released. All physical models depicting designs for any Samsung phone product, tablet product, or touchscreen digital media player, regardless of where sold, whether for a final design or an alternative design that was not commercially released. Products currently under development and not yet released may be omitted. Apple will add this to the agenda for the lead counsel meet-and-confer expected next week, unless the parties reach agreement upon the scope and timing of this production in advance. Sincerely, /s/ Mia Mazza Mia Mazza sf-3088216

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